ML20058P577
| ML20058P577 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1990 |
| From: | Donnelly L NRC OFFICE OF LICENSING SUPPORT SYSTEM ADMINISTRATOR (LSSA) |
| To: | Bartlett J ENERGY, DEPT. OF |
| Shared Package | |
| ML20058P576 | List: |
| References | |
| NACLSSAR, NUDOCS 9008170175 | |
| Download: ML20058P577 (4) | |
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1 NUCLEAR REGLA.ATORY COMMISSION
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p OFFICE OF THE -
LSS ADMINISTRATOR -
August 13, 1990 I
Dr. John W. Bartlett,_ Director Office ~of' Civilian Radioactive Waste Management U.S.' Department of Energy 1000> Independence Avenue, S.W.
o Forrestal Building
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-Washington, D.C.
20585 i
Dear Dr. Bartlett:
I ~am responding to your July-20, 199010tter, to me on the Licensing Support System development schedule.
It provides-notification-of 4
your. decision to stop work on the LSS in FY 1991 and FY 1992 and then to resume LSS development activities cuch that a pilot system 1
would be implemented and ready for testing in FY :1995 -- Your letter mentions two specific reasons for stopping work on the LSS.
- First, you believe'the-LSS procurement cannot go forward until you have j
established adequate controls over your. program information.
Second, you raise a question about being ablerto sustain funding -
for the LSS procurement in today's budget environment.
L on-your first
- point, you describe the 'need -to establish comprehensive and program-wide control of technical data, the' need 1
to develop plans for the relevancy screening of potential ~ LSS documents that are now backlogged,-and the need'to-implement your quality assurance program.
You asserti that completing _ ' these i
activities 'are critical prerequisites to. the LSS : procurement and-that it is part of the necessary framework for an'LSS-pilot; system..
I disagree.
While work in these-areas is important, it is neither.
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a critical path item nor ' a' necessary part of the front end framework needed to develop an : RFP, select a contracto?:, and implement an LSS pilot system.
. Resolving inadequacies b DOE's plans and programs that control thu gality of inforr.ation are clearly database loading prerequisites, but they are 'not in any_ way design, procurement, and pilot system testing issues.
If you are concerned about the LSS being ready _ for loading before DOE information is ready, I would. emphasize that under the earliest design an( 'avelopment schedule, nid-1994 is the first point-that the LSS database would be availaole for loading.
Your delayed schedule implies that.you will have made sufficient plans and th0fM g C
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i Dr. John W.
Bartlett August 13, 1990 i
established controls over' your information well in advance of this.
date.
Therefore, I.see no basis for delaying LSS development.
Your second point addresses the is;ue of uncertain personnel and funding levels for your program, caused in part by the lawsuits with Nevada, which translate into a question of sustaining adequate resources for the LSS procurement.
I recognize the uncertainty factor,.but I also understand from the last meeting Frank Peters and I had with OMB, that you have the latitude within your approved program totals to allocate resources to the LSS development ef fort at the level you deem appropriate..
It really comes down to a question of priorities.
I certainly do not-want to create the impression that I either desire. or am in a position to set priorities for your program; but as the individual responsible for LSS operation, maintenance, and database integrity, I urge you to reconsider your position.
The'most concerning aspect of the two year delay is the additional risk =and expense associated.with it.
Such a delay adds undue risk to the successful loading of the 20 million pages DOE has estimated will need to be loaded into the LSS l
databasc six months prior to the submission' of its license application.
It also adds considerably to the cost ' of LSS equipment and facilities.
Using your schedule, and allowing a reasonable time to test / debug the LSS pilot and incorporate lessons learned'into later modules, system expansion could not start until FY 1996.
Then following s
DOE's current LSS. conceptual design, you would start to' install i
additional LSS modules with each having a processing capability of about'750,000- pages per year.
Under this scenario, eight modules beyond the pilot would be needed, and. they. would need to be sequentially installed every four months to. meet : workload processing demands.
Each module is a significant undertaking involving not only a lot of equipment, but adequately: prepared facilities, a large number of trained personnel, and communication links with other parts of the system.
All these components must be fully integrated and be functioning properly to accomplish the efficient processing and transmission. of -LSS data.
This implementation ~ schedule, of course, does not anticipate any procurement-delays or other difficulties.
Based on my knowledge, these kinds of problems are likely, and if encountered, they will-increase the risk, add to the expense, and in a worst case scenario, could put the LSS on the critical path to the submission of DOE's license application.
Why you would want to subject the LSS project to this kind of pressure and expense is unclear when, following our previously agreed to schedule, only four modules would need to be added beyond the pilot to load the 20- million-pages by the end of year 2000.
This approach involves far less
- risk, less oversight staf f for both NRC and DOE, and would require only about. half the expenditures for equipment, related software, and facility leases.
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Dr. John W.
Bartlett August 13, 1990-In' my view, the establishment of the LSS as early as possible can I
help you carry out your mission responsibilities.
The very existence of the LSS will promote discipline and quality in the information to be submitted, from all LSS participants.
Early use of. the LSS can help identify quality problems, such as when documents do not meet identification, preparation, and submission standards, before these problems become pervasive.
As the DOE individual who will-be periodically certifying that DOE is properly identifying and submitting data to the LSS, I know you can see the value of early feedback from the LSS on the quality and completeness of < these submissions.
I also think, with earlier implementation, you can ef fectively use the LSS to meet one of your stated objectives, which is to secure effective working relationships with external organizations having an interest in your mission.
The LSS will facilitate the availability and review of technical. information by numerous groups having a role or interest in the repository evaluation program.
I must also note that your arguments for delaying development of the LSS, create what appears to me to be a crossover between DOE's two responsibilities established by the LSS rule.
Your role as an LSS participant to properly prepare and submit information should not unduly influence DOE decisions when it fulfills its role as LSS designer and developer.
On another matter, I am in receipt of your letter to Chairman Carr that transmits a draft Memorandum of Understanding'(MOU) between NRC and DOE, relative to the interactions of the two' agencies on-the LSS.
The-Chairmar has asked me to respond to your draft MOU as the person in the WRC responsible, under 10 CFR 2.1011,-for administration, management, and operation of the LSS.
This draft MOU is neither realistic nor workable and largely ignores the points in my draf t MOU that was sent to your staff in January 1990.
A fundamental agreement is necessary to establish a framework to move forward with negotiation of an MOU'.
We must agree that design and development, while your responsibility, is only one component of the total system and that given my responsibilities, I must be a full partner in the design and-development decisions that bear-on the timely and successful operation of the system as a whole.
This is necessary because I am responsible for ensuring that all the components of the LSS--design and development, the collection of documentary materials from all
- parties, and operation / maintenance--are effectively integrated to make the LSS a success from all perspectives.
The detailed provisions of the MOU must recognize this fundamental responsibility and be changed to establish appropriate levels of communication, ef fective methods of interaction, and a realistic schedule for.the transfer of the LSS to my office for operation and maintenance purposes.
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7 Dr. John W. Bartlett August 13, 1990 Given that we still have major differences with respect to a proper developrant schedule for the LSS pilot system-and our respective.
roles as prescribed in the LSS rule, I believe we should meet again to try and reconcile these differences.
I will be contacting-your office to schedule such a meeting in the next few days,
' Sincerely, oe Lloyd Donnelly LSS Administrator cca Samuel Rousso, DOE John Hoyle, NRC i
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